Redefine|BDL Hotels PRIVACY POLICY

OUR COMMITMENT

Our first priority is to offer You exceptional stays at our hotels and we recognise that your privacy forms part of our commitment to our guests. Our Guest Privacy Policy is outlined below which describes how Redefine|BDL Hotels operated hotels use your personal information in accordance with the Data Protection Act (1998).

CONSENT TO THIS GUEST PRIVACY POLICY

Please read our Guest Privacy Policy carefully before providing us with any of your "Personal Information" (hereinafter referred to as "PI"), i.e. any information collected and recorded in any format that identifies You personally, whether directly (e.g. name) or indirectly (e.g. phone number).

This Hotel Guest Privacy Policy is part of Redefine|BDL Hotels terms and conditions governing our hotel services. By accepting said terms and conditions, You expressly consent to this Guest Privacy Policy.

WHAT PERSONAL INFORMATION IS COLLECTED BY Redefine|BDL Hotels?

As a guest at a Redefine|BDL Hotels owned and/or managed hotel, You may be asked, at various times, to provide PI about Yourself and Your family members, such as:

Membership card numbers of any loyalty program or any membership number of frequent flyer or any Redefine|BDL Hotels Partner. This may include but is not limited to, IHG Priority Club, Wyndham Rewards, Accor Le Club, Starwood Preferred Guest, BEST WESTERN Rewards and Hilton Honors programmes.

Any questions/comments You may have during or after Your stay in one of our hotels.

We do not knowingly collect PI from children under the age of 18, except name, date of birth and nationality as provided directly by an adult on their behalf or with adult's permission.

Please make sure that Your children do not provide us with any PI without Your permission, e.g. online. If You believe Your child has submitted PI to us, please contact us so that we can delete such PI.

Generally, we do not knowingly collect sensitive information such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health or sex life details.

In addition, depending on the applicable law, other data than those listed above may also be considered as sensitive data: credit card number, leisure habits, personal activities and hobbies, cultural habits, smoker/ non-smoker status, etc.

However, we may need to collect such data which may be considered as sensitive, to satisfy Your request or provide You with specific services such as specific diet or any disability access facilities. In such case, if required by applicable law, we will ask You to expressly consent that we collect and process such sensitive information.

WHEN IS MY PERSONAL INFORMATION COLLECTED? PI may be collected in certain circumstances including without limitation as follows: Hospitality activities such as:

To send You newsletters, promotions and marketing material or contact you about tourism, hospitality or services, hotel promotions, or about Redefine BDL Hotels partners

You can choose to unsubscribe from our Email Newsletters service by clicking a link in one of our email newsletters

To improve our services, including:

To conduct surveys and analyse guests' questionnaires and comments and activity patterns

To manage guests' complaints

To let you benefit from our loyalty program

To secure and improve Your use of Internet websites, including:

To improve website navigation To implement security and fraud prevention meansTo comply with local regulations (e.g. retention of business or accounting documents)

SHARING OF YOUR PERSONAL INFORMATION

At Redefine|BDL Hotels, we wish to offer you the same level of service and hospitality across all our owned and managed properties across the UK.

To this end, subject to Your rights set forth below, we may have to share Your PI with internal or external recipients in the following ways:

The Redefine|BDL Hotels estate: we may share Your PI with any Redefine|BDL Hotels owned or managed entity or authorized individuals who need to access Your PI to provide You with the requested services or in the context of an action as a consequence of You providing such PI.

Any relevant individuals of the Redefine BDL Hotels entities for specific categories of data.

External service providers and partners: we may share Your PI with third parties for providing You with the requested services and improving Your stay with us.

Third party service providers: IT subcontractors , commercial Partners, local authorities – internal investigations

We may also share information with local authorities if required by local law or as part of internal investigations within the RedefineIBDL Hotels estate in compliance with local regulations.

INTERNATIONAL TRANSFERS

We may transfer Your PI to recipients, internal or external, which may be located in countries with different levels of PI protection.

Therefore, in addition to the implementation of the present Hotel Guest Privacy Policy, Redefine|BDL Hotels implements appropriate measures, including contractual clauses, to secure transfer of Your PI to any Redefine|BDL Hotels entity or external recipient located in a country with a level of protection different from the one existing in the country in which the PI is collected.

DATA SECURITY

Redefine|BDL Hotels takes appropriate technical and organisational measures, in accordance with local law requirements, to protect Your PI against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. To this end, we have implemented technical measures such as firewalls and organisational measures such as a login/efficient password system, physical protection, etc. You may have to enter Your credit card details to complete Your reservations; in such event, Redefine|BDL Hotels uses Secure Socket Layer (SSL) technology to encrypt such PI.

DATA STORAGE

We will store Your PI only for the time necessary for the purposes stated in this Hotel Guest Privacy Policy, or as permitted by the applicable law.

ACCESS AND MODIFICATION

You have the right to access, modify or delete Your PI. You can also object to the processing of Your PI as described in this Hotel Guest Privacy Policy provided that You have legitimate reasons. However, please note that if You object, we may in certain circumstances be unable to provide You with the service requested. If You wish to exercise Your rights on Your PI held by a specific hotel, then You must contact the hotel directly.

To object to the processing of Your PI for marketing purposes or if You encounter any problem when exercising Your rights, You can contact the dedicated Guest Data Services department of the Redefine BDL Hotels Group, contactable on 00 44 (0) 141 419 4567 or at Guest Data Services, Central Marketing Team, Redefine|BDL Hotels, 40 Brand Street, Glasgow, Scotland, United Kingdom, G51 1DG.

In the interests of protecting the privacy of all the Redefine BDL Hotels Group's guests, we will need to identify You properly prior to responding to Your request.

To this end, we may request a copy of a valid identification paper such as a current driver's license, identity card or passport.

If Your PI is not accurate, complete or up to date, please provide the Redefine|BDL Hotels Dpt. Data Privacy with Your request for correction. Any requests for correction will be dealt with as soon as practicable or in compliance with applicable law at the contact details outlined above.

UPDATES

We may amend this Hotel Guest Privacy Policy from time to time as indicated below. Therefore, we invite You to read this Hotel Guest Privacy Policy regularly and in any event when making a reservation in one of our Hotels. This Hotel Guest Privacy Policy was last updated on April 2015.

QUESTIONS / CONTACT

The full name of our company is Redefine|BDL Hotels UK Ltd.

We are registered in Scotland under registration number SC209059. Our registered address is 40 Brand Street, Glasgow G51 1DG. You can contact us by telephone on 0141 419 4567. Our VAT number is 100 1077 91.